Law School Case Brief
Strickler v. Greene - 527 U.S. 263, 119 S. Ct. 1936 (1999)
There are three components of a true Brady violation: the evidence at issue must be favorable to the accused, either because it is exculpatory, or because it is impeaching; that evidence must have been suppressed by the state, either willfully or inadvertently; and prejudice must have ensued.
The Commonwealth of Virginia charged defendant Tommy David Strickler with capital murder and related crimes. Because an open file policy gave Strickler access to all of the evidence in the prosecutor's files, Strickler's counsel did not file a pretrial motion for discovery of possible exculpatory evidence. At the trial, Anne Stoltzfus gave detailed eyewitness testimony about the crimes and Strickler's role as one of the perpetrators. The prosecutor failed to disclose exculpatory materials in the police files, consisting of notes taken by a detective during interviews with Stoltzfus, and letters written by Stoltzfus to the detective, that cast serious doubt on significant portions of her testimony. The jury found defendant guilty, and he was sentenced to death, the sentence of which was affirmed by the Virginia Supreme Court. In subsequent state habeas corpus proceedings, Strickler advanced an ineffective assistance of counsel claim based, in part, on trial counsel's failure to file a motion under Brady v. Maryland, 373 U.S. 83, 10 L. Ed. 2d 215, 83 S. Ct. 1194, for disclosure of all exculpatory evidence known to the prosecution or in its possession. In response, the Commonwealth asserted that such a motion was unnecessary because of the prosecutor's open file policy. The trial court denied habeas relief. The Virginia Supreme Court affirmed. Strickler then filed a federal habeas petition and was granted access to the exculpatory Stoltzfus materials for the first time. The District Court vacated Strickler's capital murder conviction and death sentence on the grounds that the Commonwealth had failed to disclose those materials and that Strickler had not, in consequence, received a fair trial. The United States Court of Appeals for the Fourth Circuit reversed because Strickler had procedurally defaulted his Brady claim by not raising it at his trial or in the state collateral proceedings. In addition, the Fourth Circuit concluded that the claim was, in any event, without merit. Defendant Strickler filed a petition for certiorari review.
Were all the three components of a true Brady violation present in this case?
After reviewing Cthe record, the United States Supreme Court found the evidence at issue was exculpatory and not disclosed. Although Strickler's Brady claim was procedurally defaulted, Strickler demonstrated cause for failing to timely raise his claim because the Commonwealth withheld exculpatory evidence, Strickler reasonably relied on the prosecutor's open file policy, and the prosecutor confirmed Strickler's reliance on the open file policy was reasonable during state habeas proceedings. Regardless, the ourt concluded Strickler did not show a reasonable probability that his conviction or sentence would have been different had the evidence been disclosed. Strickler therefore could not show materiality under Brady or prejudice from his failure to timely raise the claim. The appellate court's judgment denying Strickler's application for writ of habeas corpus was thus affirmed.
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